Justia Constitutional Law Opinion Summaries

Defendant entered a conditional guilty plea to armed bank robbery and related firearm charges. Defendant appealed the denial of his motion to suppress evidence seized during a warrantless search of a residence by police. At issue on appeal was whether the police had a reasonable belief that another man, Tommy Smith, lived at and would be present at the residence when they entered the residence in order to execute an arrest warrant for Smith. The First Circuit affirmed, holding that it was reasonable for the police to believe that Smith lived at the residence and that he would be there at the time of the police entry. View "United States v. Hamilton" on Justia Law

Petitioners, a group of individuals and advocacy groups, filed a petition challenging the constitutionality of Article 68 of the Civil Code of Puerto Rico and other laws of the Commonwealth that prohibit same-sex couples from marrying. After the lower court dismissed Petitioners’ claims, the United States Supreme Court decided Obergefell v. Hodges. All parties subsequently agreed that the Commonwealth’s ban on same-sex marriage was unconstitutional. The First Circuit agreed and vacated the judgment. On remand, however, the district court did not enter judgment in favor of Petitioners but, instead, issued a memorandum concluding that the Commonwealth’s ban was not unconstitutional because the “right to same-sex marriage” had not been determined to apply in Puerto Rico. Petitioners requested a writ of mandamus requiring the district court to enter judgment in their favor striking down the ban as unconstitutional. Respondents moved for leave to join in Petitioners’ request. The First Circuit granted Petitioners’ petition for writ of mandamus and Respondents’ motion to join in the petition, holding that the district court erred in ruling that the ban is not unconstitutional and directly contradicted the First Circuit’s mandate and compounded its error by failing to enter a final judgment to enable an appeal in ordinary course. View "In re Conde-Vidal" on Justia Law

Plaintiff filed a discrimination and retaliation suit against his Employer, alleging illegal harassment, discrimination and retaliation. Employer filed a motion for summary judgment, arguing that it did not employ the minimum number of employees necessary to qualify as an “employer” under either the Americans with Disabilities Act (ADA) or the Age Discrimination in Employment Act (ADEA). Plaintiff filed a memorandum in opposition to Employer’s motion for summary judgment, attaching a post-discovery sworn statement in support of his opposition. Employer requested that the district court strike the sworn statement. The district court granted Employer’s motions for summary judgment and to strike Employer’s sworn statement under the sham affidavit doctrine. The district court then sanctioned Plaintiff’s counsel for filing the sham affidavit after he received repeated warnings in earlier cases not to do so. The First Circuit affirmed, holding that the district court did not abuse its discretion in (1) striking Plaintiff’s sworn statement; (2) granting summary judgment to Employer on the basis that Plaintiff did not meet his burden of showing that Employer had enough employees to qualify as a covered employer under either the ADA or ADEA; and (3) ordering sanctions. View "Escribano-Reyes v. Prof’l HEPA Certificate Corp." on Justia Law

After a jury trial in federal district court, Defendant was convicted of sex trafficking and transporting minors to engage in prostitution. The First Circuit affirmed, holding (1) Defendant’s argument that the indictment was defective based on its failure to allege facts to support the aiding and abetting charges failed because Defendant could not show plain error and because any error would be harmless; (2) the district court did not abuse its discretion in denying Defendant’s motion to exclude evidence from the victim’s cell phone; (3) the district court did not abuse its discretion in denying Defendant’s motion for production of classified Department of Children and Families records that would purportedly show that the victim had previously offered men sex in exchange for a place to stay; (4) the district court did not abuse its discretion in admitting evidence that Defendant had prostituted and physically abused another woman; (5) the government did not commit misconduct in its closing argument by impermissibly commenting on Defendant’s failure to take the stand; and (6) the district court did not commit plain error in instructing the jury regarding the knowledge requirement of 18 U.S.C. 1591(a). View "United States v. Gemma" on Justia Law

After a jury trial, Defendant was convicted of possession of a controlled substance with intent to distribute and possession of a firearm in furtherance of a drug trafficking crime. Defendant appealed, challenging the district court’s denial of his motion to suppress evidence obtained after a police officer, during the course of a Terry stop, conducted a pat-frisk of a fanny pack that Defendant was wearing. The First Circuit affirmed, holding that the district court did not err in finding that the facts were sufficient to give rise to a reasonable suspicion that Defendant was armed and dangerous, and therefore, the law enforcement officer was justified in touching the fanny pack. View "United States v. Cardona-Vicente" on Justia Law

Defendant entered a conditional guilty plea to being a felon in possession of a firearm, reserving his right to appeal the denial of his motion to suppress. Defendant appealed, arguing that the trial court erred in failing to suppress (1) evidence obtained after a stop and frisk of Defendant; and (2) Defendant’s statement that he was “drug dealer” in answer to the booking officer’s question about his employment. The First Circuit affirmed the trial judge’s refusal to suppress the incriminating evidence and comment, holding (1) there was no constitutional violation in the stop and frisk of Defendant; and (2) the booking exception to Miranda applied to the employment question asked of Defendant. View "United States v. Sanchez" on Justia Law

Plaintiffs - all minors at the relevant times - were all trafficked through advertisements posted on Backpage.com. Plaintiffs filed suit against Backpage, alleging that Backpage tailored its website to facilitate sex traffickers’ efforts to advertise their victims on the website, leading to Appellants’ victimization. Specifically, Plaintiffs alleged that Backpage engaged in sex trafficking of minors as defined by the Trafficking Victims Protection Reauthorization Act and its Massachusetts counterpart, violations of Mass. Gen. Laws ch. 93A, and abridgments of intellectual property rights. The district court dismissed the action for failure to state claims upon which relief could be granted. The First Circuit affirmed, holding that the facts alleged here did not state grounds that Plaintiffs were plausibly entitled to relief on their claims. View "Doe No. 1 v. Backpage.com, LLC" on Justia Law

After a trial in 2003, Petitioner was convicted of rape in a Massachusetts state court. The Supreme Judicial Court (SJC) affirmed. In 2008, Petitioner sought a new trial claiming that his counsel on appeal had been ineffective for failing to argue that Petitioner’s speedy-trial rights had been violated. The superior court denied the motion, and the SJC affirmed. In 2013, Petitioner filed a petition for habeas corpus in federal district court, claiming that his Sixth Amendment rights to a speedy trial and effective assistance of counsel were violated during his trial. The district court denied the petition. The First Circuit affirmed, holding the SJC’s conclusion that Petitioner’s constitutional speedy-trial rights had not been violated and that Petitioner had not received ineffective assistance of counsel did not violate the standards of the Antiterrorism and Effective Death Penalty Act. View "Butler v. Mitchell" on Justia Law

After a jury trial, fugitive James “Whitey” Bulger, the former head of an organized crime syndicate in Boston, was found guilty of racketeering, the murder of eleven individuals, multiple instances of extortion and money laundering, and narcotics distribution and conspiracy. Bulger was sentenced to life in prison. Bulger appealed, alleging that he was deprived of his right to a fair trial when the trial court and the government erred in various ways both prior to and during trial. The First Circuit affirmed, holding that Bulger received a fair trial and that none of the court’s or government’s alleged errors warranted reversal of Bulger’s conviction. View "United States v. Bulger" on Justia Law

As part of an investigation into the 2008 tax liability of Defendant and his wife, the IRS served a summons on Defendant requiring him to appear for an interview and to produce banking and financial records. Defendant refused to answer any questions and did not provide the requested documents. The government filed a petition to enforce the portion of the summons seeking the production of the documents. In response, Defendant asserted a Fifth Amendment claim of privilege over his compelled act of producing the documents. The district court ultimately ordered Defendant to produce all of the requested documents, including those covered and those not covered by the Bank Secrecy Act (BSA). The First Circuit affirmed the district court’s enforcement of the summons as to documents required to be kept under the BSA and vacated the enforcement of the summons for documents not subject to the BSA, holding that a taxpayer must comply with an IRS summons for documents he or she is required to keep under the BSA, where the IRS is civilly investigating the failure to pay taxes and the matter has not been referred for criminal prosecution. View "United States v. Chen" on Justia Law